Industrial User Inspection And Sampling Manual For POTW's

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United StatesEnvironmental ProtectionAgencyEPAI n d u s t r i a lSamplingU s e rManuI n s p e c t i o nalForPOTA n dW's

IndustrialUserInspectionM a n u a lf o randSamplingP O T W sPrepared by:The Office of Wastewater Enforcement and ComplianceWater Enforcement DivisionU.S. Environmental Protection AgencyWashington, D.C. 20460April, 1994

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYWASHINGTON, D.C. 20460MEMORANDUMSUBJECT:Transmittal of the Final Industrial User Inspection and Sampling ManualFROM:Michael B. Cook, DirectorOffice of Wastewater Enforcement andTO:Water Management Division DirectorsRegions I-XI am pleased to provide the final Industrial User Inspection and Sampling Manual.The manual represents the culmination of almost two years of effort on the part of variousoffices within EPA Headquarters, and is the result of substantial comments from the EPARegional Water Management Divisions, the Office of Research and Development inCincinnati, AMSA members, and other interested parties. We appreciate the extensiveeffort in providing comments on the previous two drafts. Your insight significantlyimproved the document, and we are confident that the manual will be extremely useful toPOTW inspection and sampling personnel.The final document includes the second round of comments made by the Regions.The most significant change made to the document as a result of Regional comment is thedeletion of the discussion on determining compliance with the 4-day average standard underthe Electroplating regulation. The method for determining compliance with theElectroplating standard may be addressed through a policy paper at a later date. A secondsignificant change is the deletion of the discussion on determining compliance from sampleresults below detection. The reason that we deleted this discussion is that the national workgroup addressing this issue has delayed its time frame for making a recommendation onhow to address compliance in these situations. Therefore, any discussion of this matter willneed to wait until the national work group has reached its conclusion.We are expecting to conduct a mass-mailing of the document to all POTWs withapproved pretreatment programs in late spring or early summer depending on the amount oftime it takes to have the document printed. If you have any questions regarding the manualor its distribution, please feel free to call Lee Okster at (202) 260-8329.cc:Cynthia DoughertyRegional Pretreatment CoordinatorsFred Stiehl - OEKen Kirk - AMSA

PrefacePOTW Inspection and Sampling ManualDisclaimerThis manual has been written by the Office of Wastewater Enforcement and Compliance, U.S. EnvironmentalProtection Agency, and has been peer reviewed both within the EPA and outside of the EPA. This guidancerepresents the EPA’s recommended procedures to be used by POTW personnel when conducting an inspectionor sampling visit at an industrial user. A failure on the part of any duly authorized POTW official, inspector, oragent to comply with the contents of the manual shall not be a defense in any enforcement action taken againstan IU, nor shall a failure to comply with this guidance alone constitute grounds for rendering evidence obtainedin the inspection inadmissible in a court of law. Any mention of trade names or commercial products is neitheran endorsement nor a recommendation for use.

POTW inspection and Sampling ManualPrefaceAcknowledgementsThis manual was written by the Office of Wastewater Enforcement and Compliance, U.S. EnvironmentalProtection Agency, under the direction of Lee Okster. The Office of Wastewater Enforcement and Compliancewould like to acknowledge the considerable efforts and cooperation of the following individuals, whosecontribution helped to complete this document successfully: Mr. Paul Marshall (Region VII RetreatmentCoordinator) for use of his checklist for inspecting industrial users; the EPA Regional Pretreatment Coordinatorsfor insightful comments on the draft document; Mr. Sam Hadeed and members of the Association of MetropolitanSewerage Agencies (AMSA) who provided comments on the draft document; Mr. William Potter of the EPA’sOffice of Research and Development in Cincinnati; Mr. Jack Stoecker of Brown and Caldwell; and Ms. NadineSteinberg of the EPA’s Office of Enforcement.

T a b l eo fC o n t e n t sDisclaimeriAcknowledgementsiiList of TablesviiList of FiguresviiiDefinitions and Acronyms Used in the Pretreatment ProgramixI. Introduction1Inspections and Sampling in the Pretreatment ProgramLegal Authority and Regulatory Basis for ConductingIndustrial User Inspections and Outline of the Guidance1Users2356I I . Inspecting Industrial UsersIntroductionDeveloping and Maintaining an IU SurveyFrequency of Inspections and SamplingTypes of InspectionsConfidential Business InformationResponsibilities of the InspectorInspector's Field NotebookPre-Inspection Activities- Pre-Inspection PreparationReview of Facility Background InformationDeveloping an Inspection PlanSafety and Sampling Equipment PreparationNotification of the FacilityEntry to the Industrial User- Legal Basis for Entry- Arrival for the InspectionReluctant to Give ConsentUncredentialed Persons Accompanying the InspectorAccess to Federal FacilitiesDenial of Consent to EnterWithdrawal of Consent to EnterDenial of Access to Parts of the FacilityCovert Sampling in Response to Denial of EntryConducting an Inspection Under a WarrantPre-Inspection ChecklistPre-Inspection ctionOn-Site Activities- Opening Conference- Inspection Procedures-iii-67789111416222829293132

T a b l eo fC o n t e n t s( c o n t . )Physical Plant ReviewSelf-Monitoring ReviewOperations EvaluationMaintenance EvaluationRecords Review at the Industrial UserObtaining Copies of Necessary RecordsRecord Identification Procedures- Closing ConferenceFollow-Up Activities- Inspection ReportInspection Checklist454853I I I . Sampling Industrial UsersIntroductionAnalytical MethodsQuality Assurance and Sampling PlanStandard Operating ProceduresPre-Sampling ActivitiesCleaning and Preparation of Sampling EquipmentCleaning Procedures for Conventional PollutantsCleaning Procedures for MetalsCleaning Procedures for Oil and GreaseCleaning Procedures for Organic AnalysesVolatile Organic CompoundsSemi-Volatile Organic Compounds, Organochlorine Pesticides& PCBsCleaning of Automatic Sampling EquipmentPreparing Field InstrumentsPh MetersResidual Chlorine MetersTemperatureDissolved OxygenSelection and Preparation of Sample ContainersType of SampleOn-Site ActivitiesSampling LocationSample Collection TechniquesSample VolumeSample Preservation and Holding TimesSample DocumentationSample Identification and LabelingChain-of-CustodySample Packaging and ShippingQuality ControlS a f e t y C o n s i d e r a t i o n s D u r i n g S a m p l i n gPhysical HazardsAtmospheric HazardsOxygen Deficient Atmosphere-iv-53555658607179

T a b l eo fC o n t e n t s( c o n t . )Explosive AtmosphereToxic Atmosphere- Safety EquipmentProtective ClothingTraffic ControlRadioAir Monitoring DevicesVentilation DevicesSafety Harness and Retrieval SystemRespirators- Confined Space Entry- Safety TrainingFlow Measurement- Open Channel FlowPrimary DevicesSecondary Devices- Closed Channel FlowQuality Assurance and Quality Control- Quality Control Procedures for Sampling- Quality Assurance Procedures for Sampling- Laboratory Quality Assurance and Quality ControlCompliance Issues Related to Industrial User Sampling- The Use of Duplicate Samples to Evaluate Compliance- Compliance With Monthly Average Limitations- Closed Cup Flashpoint Sampling and Compliance- Frequency of POTW Sampling In Lieu of Industrial User Sampling- SNC in Situations of Multiple Outfalls- Violation Date- Compliance With Continuous Monitoring of l Industrial Inspection QuestionsIndustry Specific QuestionsGeneral Operations and Maintenance QuestionsHazard Associated With Specific Industrial CategoriesEPA Memorandum ‘The Use of Grab Samples to Detect Violations of Pretreatment Standards."Now Measurement TechniquesEPA Memorandum, “‘Determining Industrial User Noncompliance Using Split Samples”Compliance With Continuous Monitoring of pHExample Standard Operating ProceduresExample Sample Tag and Chain-of-Custody Form for Use by POTWsList of Regional Pretreatment CoordinatorsList of Available Pretreatment Guidance Documents40 CFR Part 136 - Tables IA, IB, IC, ID, IE and II-v-889499104

List of TablesTable # and TitlePage #2-1Procedural Responsibilities of the POTW Inspector . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .132-2Knowledge and Skills Required of Pretreatment Inspectors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .152-3Information to Review Prior to the Inspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 182-4“Generic” Elements of an Inspection Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-5Pre-Inspection Checklists3-1Checklist of Field Sampling Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3-2Composite Sampling Methods3-3Volume of Sample Required for Analyzing Various Industrial Pollutants . . . . . . . . . . . . . . . . . . . 1073-4Required Containers, Preservation Techniques, Holding Times. and Test Methods . . . . . . . . . . . . 109VI-1Head-Discharge Relationship Formulas for Nonsubmerged Weirs . . . . . . . . . . . . . . . . . . . . . . .VI-3VI-2Discharge of 90 V-Notch Weir -- Head Measured at Weir Plate . . . . . . . . . . . . . . . . . . . . . . .VI-4VI-5Flow Rates for 60 and 90 V-Notch WeirsVI-3Minimum and Maximum Recommended Flow Rates for Cipolletti Weirs . . . . . . . . . . . . . . . . . . .VI-7VI-4 Minimum and Maximum Flow Rates for Free Flow Through Parshall Flumes . . . . . . . . . . . . . .VI-721. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30.617 0. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VI-5VI-5 Free Flow Values of C and N for Parshall Flume Based on the Relationship Q CWH.” . . . . . .VI-11VI-6 Minimum and Maximum Recommended Flow Rates for Free Flow ThroughPlast-Fab Palmer-Bowlus Flumes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VI-13VI-7 Coefficients of Discharge c for Venturi MetersVI-8.VI-15Values of K in Formula for Venturi Meters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .VI-15VI-9 Advantages and Disadvantages of Secondary Devices-vi-.VI-17

List of FiguresFigure # and TitlePage #2-1Example of a Deficiency Notice473-1Metals Cleaning Procedures613-2Atmospheric Constituents803-4Profile and Nomenclature of Sharp-Crested Weirs903-5Four Common Types of Sharp-Crested Weirs913-6Plan View and Cross Section of a Parshall Flume923-7Free-Flowing Palmer-Bowlus Flume933-8Configuration and Nomenclature of a Venturi Meter933-9Electromagnetic Flow Meter95VI-2Nomograph for the Capacity of Rectangular WeirsVI-6VI-3Flow Curves for Parshall FlumesVI-8VI-4 Dimensions and Capacities of Parshall Flumes for Various Throat WidthsVI-9VI-5VI-12Effect of Submergence on Parshall Flume Free-Discharge-vii-

Definitions and Acronyms Used in the Pretreatment Program1)AccuracyAccuracy refers to the degree of difference between observed values and known or actual value in theanalysis of wastewater.2)Act or “the Act”The Federal Water Pollution Control Act. also known as the Clean Water Act, as amended, 33 U.S.C.§125 et.seq.3)Acute EffectsWhen the effects of an exposure to a pollutant (over a short period of time) cause severe health effects tohumans or other organisms, this condition is said to be acute (compare to chronic below).4)Baseline Monitoring Report (BMR) [40 CFR 403.12(b)]All new source industrial users subject to categorical standards must submit a baseline monitoring report(BMR) to the Control Authority (POTW, State or EPA) at least 90 days prior to the commencement ofdischarge. The purpose of the BMR is to provide initial information to the Control Authority includingidentifying information, description of existing environmental permits, description of operations, flowmeasurements (estimated), and the concentration of pollutants in the waste stream (estimated). Existingsources were required to submit BMRs within 180 days after the effective date of any applicablecategorical standard.Batch ProcessA treatment or manufacturing process in which a tank or reactor is filled, the wastewater (or solution) isheld or a chemical solution is prepared, and the tank is emptied, resulting in a discrete discharge to thesanitary sewer. The tank may then be refilled and the process repeated. Batch processes are also used toclean, stabilize, or condition chemical solutions for use in industrial manufacturing and treatmentprocesses.6)Biochemical Oxygen Demand (BOD)The quantity of oxygen utilized in the biochemical oxidation of organic matter under standard laboratoryprocedures for five (5) days at 20 centigrade, usually expressed as a concentration (e.g. mg/l). BODmeasurements are used to indicate the organic “strength” of wastewater.7)Biological TreatmentA waste treatment process by which bacteria and other microorganisms break down complex organic orinorganic (e.g., ammonia) materials into simple, nontoxic, more stable compounds.8)Blank (Bottle)Is an aliquot of analyte-free water which is taken through the appropriate steps of the analytic process asa means of determining if the sampling container is introducing contamination into the sample. Foraqueous samples, reagent water is used as a blank matrix; however, a universal blank matrix does notexist for solid samples (e.g., sludge), and therefore, no matrix is used.9)Blank (Equipment)Is an aliquot of analyte-free water which is taken to and opened in the field. The contents of the blankare poured appropriately over or through the sample collection device, collected in a sample container,-viii-

POTW Inspection and Sampling ManualDefinitionsand returned to the laboratory as a sample to be analyzed. Equipment blanks are a check on the samplingdevice cleanliness.10) Blank (Field)Is an aliquot of analyte-free water or solvent brought to the field in sealed containers and transportedback to the laboratory with the sample containers and analyzed along with the field samples.11) Blank (Method)Is an aliquot of analyte-free water prepared in the laboratory and analyzed by the analytical method usedfor field samples. Method blanks are used to test for the cleanliness of reagents, instruments, and thelaboratory environment.12) Blank (Sample Preservation)Is an aliquot of analyte-free water (usually distilled water) to which a known quantity of preservative isadded. This type of sample is a means of determining the level of contamination of acid and chemicalpreservatives after a period of use in the field.13) BlowdownThe discharge of water with high concentrations of accumulated solids from boilers to prevent pluggingof the boiler tubes and/or steam lines. In cooling towers, blowdown is discharged to reduce theconcentration of dissolved salts in the recirculating cooling water. Clean “make-up” water is added todilute the dissolved solids in the system. Blowdown also includes the discharge of condensate.14) Categorical Industrial User (CIU)A categorical industrial user is an industrial user (see IU definition below) which is subject to acategorical standard promulgated by the U.S. EPA.15) Categorical Standards (40 CFR 405-471)Any regulation containing pollutant discharge limits promulgated by the EPA in accordance with Sections307(b) and (c) of the Act (33 U.S.C. §1317) which apply to a specific category of users and whichappear in 40 CFR Chapter I, Subchapter N, Parts 405-471.16) Centralized Waste Treatment Facility (CWT)A public or private facility which treats hazardous and other wastes. These facilities are designed tohandle the treatment of specific hazardous wastes from industry. The waste waters containing thehazardous substances are transported to the facility for proper storage, treatment and disposal.17) Chain of CustodyA legal record (which may be a series of records) of each person who had possession of anenvironmental sample, from the person who collected the sample to the person who analyzed the samplein the laboratory and to the person who witnessed the disposal of the sample.18) Chemical Oxygen Demand (COD)Chemical oxygen demand is expressed as the amount of oxygen consumed from the oxidation of achemical during a specific test (in mg/L). As such, COD is a measure of the oxygen-consuming capacityof the organic matter present in the wastewater. The results of the COD test are not necessarily related tothe Biochemical Oxygen Demand (BOD) because the chemical oxidant responsible for utilizing theoxygen may react with substances which bacteria do not stabilize.-ix-

POTW Inspection and Sampling ManualDefinitions19) Chemical Treatment ProcasA waste treatment process which involves the addition of chemicals to achieve a desired level of ef?luentquality.20) Chronic EffectsWhen the effect of a single or repeated exposure(s) to a pollutant causes health effects over a long periodof time in humans or other organisms this is said to be a chronic condition (compare to acute above).21) Code of Federal Retwlations (CFRIA publication of the United States government which contains all of the final&d federal regulations.Federal environmental regulations are found in volume 40 of the CFR. and the General PretreatmentRegulations are found at 40 CFR Part 403.22) Combined Wastestream Formula (CWFI 140 CFR 403.6(eAThe combined wastestream formula is a means of deriving alternative categorical discharge limits insituations where process emuent is mixed with waste waters other than those generated by the regulatedprocess prior to treatment.23) Couwosite Proportional) Sam&sA composite sample is a collection of individual grab samples obtained at regular intervals, either basedon time intervals or flow intervals (e.g., every two hours during a 24-hour time span or every 1000gallons of process wastewater produced). Each individual grab sample is either combined with the othersor analyzed individually and the results averaged. In time composite sampling the samples are collectedafter qua1 time intervals and combined in proportion to the rate of flow when the sample was collected.Flow composite sampling can be produced in one of two ways. The first method of obtaining a flowcomposite sample is to collect equal volume individual grab samples after a specific volume of flowpasses the sampling point. The second manner of obtaining flow composite sample is to vary the volumeof the aliquot collected in proportion to the amount of flow that passed over the time interval which thesample represents. Composite samples are designed to be representative of the emuent conditions byreflecting the average conditions during the entire sampling period (compare grab sample).24) Confined SpaceA space which, by design, has limited openings for entry and exit, unfavorable natural ventilation whichcould contain or produce dangerous air contaminants (or create an atmosphere of oxygen deprivation),and which is not intended for conlinuous employee occupation. A permit may be required under OSHAto enter a confined space.25) Conservative Pollu rantA pollutant found in wastewater that is not metabolized while passing through the treatment processes ina conventional wastewater treatment plant. Therefore, a mass balance can be constru

III.Sampling Industrial Users 53 Introduction Analytical Methods Quality Assurance and Sampling Plan Standard Operating Procedures Pre-Sampling Activities Cleaning and Preparation of Sampling Equipment Cleaning Procedures for Conventional Pollutants Cleaning Procedures for Metals Cleaning Procedures for Oil and Grease Cleaning Procedures for .

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